2016-04-14_PERMIT FILE - M2016009 (3)

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-(VD RECEIVED April 13, 2016 "PR 14 2016 Division of Reclamation, Division of Reclamation,Mining, and Safety M,,,4Nkq&S Qy 1313 Sherman Street Room 215 rn alb Denver,CO. 80203 0 RE: "4411 Lane Project"at or near Section 19,Township 21 South,Range 62 West, 6t"Prime Meridian Sear Sirs/Madams, I am contacting you to express my serious concerns over issuance of a Construction Materials Operation Reclamation permit to Fremont Paving and Redi-Mix Inc. of Caflon City(Fremont Paving). We are familiar with the area--known locally as the Badger Hills--where Fremont Paving wishes to extract gravel. This area is immediately adjacent to a prime agricultural region of eastern Pueblo County. The soils in this area are classified as"prime irrigated soils of national importance". The Bessemer Ditch, which irrigates these lands flows from the Pueblo reservoir nearly 40 miles to the Huerfano River. Approximately 20,000 acres are irrigated by this ditch. The area where Fremont Paving proposes to set up their operation is uphill of and within a couple hundred feet of this irrigation ditch. In recent years,Pueblo County has had some devastating flood events as a result high rainfall in short periods of time. For example two of the last three years, we had 4-5"of rainfall within a 24 hour period. These events resulted in severe erosion around the County and major issues for the Bessemer Ditch. The location of the"441h Lane Project" is situated in an ecologically fragile area,which is highly susceptible to erosion. We are very concerned that the proposed operation will cause high levels erosion and directly and adversely impact production farmers. In addition,reclamation in this area will be exceedingly difficult due to scant annual rainfall and the soil type. During dry years we have witnessed first-hand the failed reclamation efforts of other projects in Pueblo County that have resulted in dust-bowl type condition in eastern Pueblo County. Dry years will surely return and a large-scale project such as the"44'Lane Project"will undoubtedly contribute significantly to blowing dust and destructive erosion,both during and after operations conclude. In summary,this is an arid and ecologically fragile area that contains some of the best irrigated agricultural land in the western United States. On behalf of our clients and the farmers of Pueblo County, — we strongly discourage the Division of Reclamation,Mining, and Safety from issuing a permit to Fremont Paving on the basis of unacceptable threats to local farming operations and the extreme difficulty of reclaiming the landscape after proposed mining operations conclude. There are many places where construction materials can be safely extracted with minimal impact to production agriculture,but this proposed site is not one of them. Thank you for your consideration, Ryan Froman Vice President, South Pueblo Soil Conservation District