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2020-03-30_PERMIT FILE - M2020008
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2020-03-30_PERMIT FILE - M2020008
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Last modified
11/17/2021 3:07:15 PM
Creation date
3/30/2020 2:03:17 PM
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Template:
DRMS Permit Index
Permit No
M2020008
IBM Index Class Name
PERMIT FILE
Doc Date
3/30/2020
Doc Name
Adequacy Concerns
From
Karp Neu Hanlon
To
DRMS
Email Name
LJW
Media Type
D
Archive
No
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Karp_Neu.HAanIYonW <br /> Page 3 <br /> As such, off site actions that harm the fish and wildlife attributes of the Island Park land are of <br /> particular concern. <br /> Lowering the groundwater table on the Scott property will impact groundwater levels and <br /> wetlands on adjoining properties thereby harming fish and wildlife off-site. Consistent with the <br /> "natural" status of the wetlands on the Scott property, its mining plan recognizes that the <br /> groundwater table in the area is a shallow 3 to 8 feet deep. Application at 26. This vital <br /> groundwater resource maintains wetlands on the Island Park property as well as other surrounding <br /> properties. Allowing Scott to lower the groundwater table as proposed in the mining plan will <br /> inappropriately damage wetlands and waterfowl habitat on the Island Park property. DRMS must <br /> make certain that any permit issued by it will not result in harm to adjoining lands. <br /> Comments from the Colorado Division of Water Resources(February 13,2020)recognize <br /> that"the dewatering activity will lower the groundwater during Phase 1 . . ." Further, as noted by <br /> DWR, Scott has failed to undertake the necessary analysis of impacts on groundwater uses within <br /> 600 feet of the permit area. All DWR concerns must be addressed prior to consideration of the <br /> Scott application. <br /> Finally,comments made by the Colorado Division of Parks and Wildlife(CPW)(February <br /> 24, 2020) stress that Scott's proposed use of the Island Park ditch lateral to send its dewatering <br /> effluent to the Colorado River puts fish and wildlife at risk. Wildlife and waterfowl on the Island <br /> Park property use the lateral ditch for habitat purposes. Sedimentation of the ditch by Scott's <br /> proposed uses will harm that habitat impacting the fish, wildlife, and waterfowl that rely on it. <br /> Even if Scott had the legal right to use the Island Park lateral ditch, Scott has failed to provide an <br /> adequate sediment management plan to allow DRMS to approve its application. <br /> IV. Other matters that must be addressed prior to issuance of a permit. <br /> Scott failed to give notice to owners within 200 feet of its property boundaries as required <br /> by Regulation 2 CCR 407-1, 1.6.2. The western boundary of the Scott property is within 200 feet <br /> of the Island Park property. Exhibit A. As such, sufficiency of notice does not allow the Scott <br /> application to proceed without being amended. <br /> The comment letter from CPW notes that the Scott property has a high concentration of <br /> noxious weeds. DRMS must impose strict requirements for sterilizing soil of noxious weed seed <br /> and provisions for ensuring that soil storage mounds on the site will not allow for the spread of <br /> weeds onto the Island Park property. <br /> Island Park reserves the right to supplement its comments in response to future information <br /> provided by the applicant or as additional information becomes available. <br />
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