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FRIENDS OF CLEAR CREEK
<br /> is a group of engaged citizens from the communities of Clear Creek County Colorado,who respect and protect the
<br /> air,water,natural landscape,wildlife,and quality of life for all who reside in and visit our beautiful county.
<br /> www.FriendsOfClearCreek.com
<br /> December 10,2018
<br /> TO: Colorado Division of Reclamation,Mining and Safety(DRMS): 1313 Sherman St#215,Denver CO 80203
<br /> ATTN: Michael Cunningham,Senior Environmental Protection Specialist: michaela.cunninsham@state.co.us
<br /> ATTN: Peter Hays,Environmental Protection Specialist:peter.hays@state.co.us
<br /> RE: Douglas Mountain Ranch Mining Project,Permit#M2018016 with the Department of Reclamation,Mining,
<br /> and Safety(DRMS)
<br /> Our communities in Clear Creek County are in opposition to the proposed Douglas Mountain Ranch Mining Project
<br /> (DMRM)currently under permit review with your office.We have written letters and sent emails to the
<br /> Department of Reclamation, Mining,and Safety for several months,after the original DMRM permit application in
<br /> July 2018,and the amended DMRM permit application in September 2018,to voice our many concerns and urge
<br /> your office to deny the permit.Our protected wildlife,water quality,air quality,and the health of our residents
<br /> and visitors would be threatened because the location of the proposed mining project is too close to established
<br /> wildlife habitats,water sources,and populated areas such as the Easter Seals Rocky Mountain Village Camp and
<br /> the Town of Empire.
<br /> We have written letters to Colorado Parks and Wildlife(CPW)voicing our concerns about the risks to our wildlife
<br /> on the Douglas Mountain Plateau,specifically the Georgetown bighorn sheep herd.Ben Kraft,a wildlife biologist
<br /> with CPW,was recently quoted on a Channel 4 newscast saying CPW's objective was to"wisely manage bighorn
<br /> habitat and make sure that habitat isn't lost,fragmented,or degraded because of our activities".CPW's 2015
<br /> Bighorn Sheep Report specifically mentions Empire Junction(the site of the proposed mine and the Kraft
<br /> interview)as high-consequence habitat where current road traffic produces the most sheep/vehicle mortality
<br /> within the entire herd and a restriction point that hinders the herd's ability to genetically intermingle. Elk,deer,
<br /> moose,black bears,and mountain lions also roam the Douglas Mountain Plateau.The threatened greenback
<br /> cutthroat trout,rainbow trout,and brown trout all swim in the waters of Clear Creek,which is fed by the West
<br /> Fork of Clear Creek that runs along the edge of the plateau.Bald eagles,golden eagles,peregrine falcons,ospreys,
<br /> and hawks all soar above the plateau,breeding and nesting on neighboring mountainsides,and hunting and
<br /> feeding on the plateau.This plateau has a rich diversity of wildlife and is important for migration corridors,nesting
<br /> areas,lambing and calving areas,winter habitat,and denning sites for many species.Removing native vegetation
<br /> on the plateau would deplete food sources for all wildlife in the area,and the lush vegetation and heavily wooded
<br /> areas on the adjoining properties would be decimated by the disruption of the natural springs and ground water.
<br /> Bighorn sheep,elk,deer,and moose are spotted and photographed daily on the plateau,drawn by the springs and
<br /> vegetation,not just on the steep mountainsides.
<br /> We have written letters to the Colorado water agencies:Division of Water Resources,Water Conservation Board,
<br /> Water Quality Control Division,and Water Quality Control Commission,voicing our concerns about the risks to the
<br /> Upper Clear Creek Watershed and the West Fork of Clear Creek,including valuable ground water and privately
<br /> held perennial natural springs adjacent to the Douglas Mountain Plateau.We believe Empire Aggregates LLC has
<br /> not addressed their full legal requirements for the project nor addressed nearby landowners'valid and obvious
<br /> concerns for their personal water resources.The mining operation will divert the ground water,natural springs,
<br /> and drainage on the plateau along with the natural flow of the West Fork of Clear Creek and Bard Creek,impacting
<br /> the West Clear Creek Watershed Basin(HUC-0103)and the property owners downstream.This is in direct violation
<br /> of the permit application which states"If mining and reclamation operations affect areas beyond the boundaries of
<br /> an approved permit boundary,substantial civil penalties can result."The applicants have not shown that the water
<br /> they plan to use for the mining operation has been obtained from a legal source;they have not shown evidence
<br /> that they have applied for a mining/industrial well permit;they have not done adequate research into the wells in
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