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2018-12-12_REVISION - M2018016 (7)
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2018-12-12_REVISION - M2018016 (7)
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Last modified
12/27/2024 7:10:03 AM
Creation date
12/12/2018 2:16:33 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2018016
IBM Index Class Name
Revision
Doc Date
12/12/2018
Doc Name Note
Impact Economic Assessment
Doc Name
Objection
From
Emily S. Andrews, Ph.D.
To
DRMS
Type & Sequence
AM1
Email Name
PSH
Media Type
D
Archive
No
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' In view of other wildlife objectives for bighorn sheep and Peregrine falcons, the <br /> balance between herd containment, hunter recreational opportunities, and wildlife <br /> concerns would appear to take precedence over the DMRM. Once again these are <br /> serious issues of unanticipated risk created by a sand and gravel pit at the DMRM <br /> site. Even with mitigation measures in place,the possibility of unforeseen events is <br /> high. A Black Swan could be possible, as it is impossible to predict what vulnerable <br /> wildlife populations will do once patterns of habitat and migration are interrupted. <br /> In the case of bighorn sheep, a single gravel mine alone could cancel out years of <br /> careful planning and extensive support instituted by the CPW and the US Forest <br /> ' Service to support the Georgetown Bighorn Herd. <br /> Risks to Water Resources <br /> The Clear Creek watershed is characterized by beautiful mountain scenery and <br /> ' outdoor recreation. Clear Creek is valued for its fisheries, and is utilized extensively <br /> for kayaking, rafting, swimming, and small-scale, recreational placer mining. It also <br /> provides the water supply for a number of Colorado communities. These uses are all <br /> ' heavily dependent upon acceptable water quality. As Clear Creek flows through the <br /> watershed, it dissolves naturally occurring minerals and, in some cases, radioactive <br /> materials from rock surfaces and the riverbed. Rockslides or landslides, runoff from <br /> forested areas, animal activity, or human activities all may affect water quality in <br /> Clear Creek. <br /> ' The 2014 Upper Clear Creek Watershed Plan Update30 indicates that contamination <br /> from past mining and milling operations is significant in Upper Clear Creek as <br /> ambient (non-storm event) metal concentrations exceed standards established to <br /> fprotect aquatic life. Certain stream segments in Clear Creek are not achieving water <br /> quality standards for trace metals and are listed as impaired. <br /> ' In 1983,because of mining-related water quality problems,the US Environmental <br /> Protection Agency (EPA) established the Clear Creek/Central City Superfund Study <br /> ' Area and placed it on the National Priority cleanup list (see also the Colorado <br /> Department of Public Health and Environment's listing). This was the beginning of a <br /> series of activities around the Clear Creek Watershed that have continued up to <br /> ' today.31 <br /> The Clear Creek Watershed Foundation (CCWF), a non-profit organization <br /> incorporated in 1997,was a result of this original EPA Superfund initiative. The <br /> Foundation conducts studies and implements programs to improve the quality of <br /> Clear Creek and its tributaries. Projects have included abandoned mine remediation, <br /> 30 htt s: www.colorado. ov acific sites f 1 - - <br /> p // g /p / ,/de au t/files�CCWatershedPlan 02 06 <br /> ' 14_FINAL.pdf <br /> 31 http://clearcreekwater.org/about-ccwf/ <br /> 13 <br />
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