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RE: Douglas Mountain Ranch Mining Project,Permit#M2018016 with the Division of Reclamation,Mining,and '
<br /> 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 Division of
<br /> Reclamation, Mining,and Safety for several months,after the original DMRM permit application in July 2018, and
<br /> the amended DMRM permit application in September 2018,to voice our many concerns and urge your office to
<br /> deny the permit.Our protected wildlife,water quality,air quality,and the health of our residents and visitors
<br /> would be threatened because the location of the proposed mining project is too close to established wildlife
<br /> habitats,water sources,and populated areas such as the Easter Seals Rocky Mountain Village Camp and the Town
<br /> 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. Rainbow trout and brown trout
<br /> swim in the waters of Clear Creek,which is fed by the West Fork of Clear Creek that runs along the edge of the
<br /> plateau. Bald eagles,golden eagles, peregrine falcons,ospreys,and hawks all soar above the plateau, breeding and
<br /> nesting on neighboring mountainsides,and hunting and feeding on the plateau.This plateau has a rich diversity of
<br /> wildlife and is important for migration corridors, nesting areas, lambing and calving areas,winter habitat,and
<br /> denning sites for many species. Removing native vegetation on the plateau would deplete food sources for all
<br /> wildlife in the area,and the lush vegetation and heavily wooded areas on the adjoining properties would be
<br /> decimated by the disruption of the natural springs and ground water. Bighorn sheep,elk, deer,and moose are
<br /> spotted and photographed daily on the plateau,drawn by the springs and vegetation, not just on the steep
<br /> 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
<br /> the area;they have not acknowledged how breaching the known shallow groundwater will destroy adjacent
<br /> springs and hinder their project mid-operation.This does not instill confidence in the residents of Clear Creek
<br /> County that the applicants will adhere to strict guidelines when it comes to exposing this groundwater and other
<br /> safety precautions to protect the groundwater,creek,and watershed area.According to the DRMS,a flood analysis
<br /> and flood control plan is needed when mining occurs within 400 feet of a river channel, as the floodplain could be
<br /> altered,and riverside berms have the potential to be damaged during flooding and are prone to erosion.The
<br /> applicants have not submitted either of the requested documents to date.
<br /> We have written letters to the Air Pollution Control Division,voicing our concerns over silica dust produced from
<br /> gravel mining and vehicle emissions from over 300 diesel trucks per day polluting our air and the respiratory risks
<br /> to The Easter Seals Rocky Mountain Village Camp,the residents of the Town of Empire,and the surrounding
<br /> residents in Clear Creek County. Easter Seals Rocky Mountain Village was established in 1951 and is directly across
<br /> the highway from this proposed mine,east and downwind of the Douglas Mountain Plateau.The dust and other
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