2018-11-30_PERMIT FILE - M2018016

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Nov 3 4 l u 18 rK DMSM OF RECLAMATION Nov MINING END WETY o^- Department of Reclamation,Mining, and Safety; Peter Hays: peter.haysca.;state.co.us RE: Douglas Mountain Ranch Mining Project, Permit#M2018016 with the Department of Reclamation, Mining, and Safety (DRMS) We write to you in opposition to the proposed Douglas Mountain Ranch Mining Project currently under permit review with the DRMS. We believe this proposed mine will damage or destroy elements of the Clear Creek Watershed, including valuable ground water and privately held perennial natural springs adjacent to the Douglas Mountain Plateau. We believe Empire Aggregates LLC has not addressed their full legal requirements for the project nor addressed nearby landowners' valid and obvious concerns for their personal water resources. Therefore, as public servants tasked with defending the state's existing water resource value, we demand you recommend denial of this project to the DRMS. The applicants have not shown that the water they plan to use for the mining operation has been obtained from a legal source; they have not shown evidence that they have applied for a mining/industrial well permit; they have not done adequate research into the wells in the area; they have not acknowledged how breaching the known shallow groundwater will destroy adjacent springs and hinder their project mid-operation.This does not instill confidence in the residents of Clear Creek County that the applicants will adhere to strict guidelines when it comes to exposing this groundwater and other safety precautions to protect the groundwater, creek, and watershed area. According to the DRMS, a flood analysis and flood control plan is needed when mining occurs within 400 feet of a river channel, as the floodplain could be altered, and riverside berms have the potential to be damaged during flooding and are prone to erosion. The applicants have not submitted either of the requested documents to date. Adjacent property owners on the Douglas Mountain Plateau have perennial springs sourced from the plateau, lush vegetation, and heavily wooded areas. Altering the drainage pattern on the plateau would divert the water away from these properties, devastating their emotional and financial value along with essential vegetation for wildlife. The plateau has a rich diversity of wildlife and is important for migration corridors, nesting areas, lambing and calving areas, winter habitat, and denning sites for many species. Removing native vegetation on the plateau would deplete food sources for all wildlife in the area, and the lush vegetation areas on the adjoining properties would be decimated by the disruption of the natural springs and ground water. Bighorn sheep, elk, deer, and moose are spotted and photographed daily on the plateau, drawn by these water resources. Our wildlife relies on this surface water for the food and cover it provides. The amended permit application to DRMS M-2018-016, states"All surface water flows that drain to the site (Douglas Mountain Plateau) currently pass across the meadow before draining to the West Fork of Clear Creek to the north. During mining,these flows will be partially intercepted by the mining activity as the operation progresses."The mining operation will divert the ground water, natural springs, and drainage on the plateau along with the natural flow of the West Fork of Clear Creek and Bard Creek, impacting the West Clear Creek