2020-12-01_GENERAL DOCUMENTS - M2020041

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To: 13038328106 Page:3 of 7 2020-12-01 23:56:54 GMT 13032008630 From:Ben Langenfeld Peak Ranch Resource December €.20-10 Peak Resources has agreed to implement mod{Jied hours for trucking operations, based on CPW recommendirtions, to minimise the potential,for wildlife-vehicle collisions during the times of•day when deer, elk and moose are most active, and specifically during the winter months when ivildirfe is concentrated at lower elevations closer to the highwat. C:1'W supports the operators proposed hours for limiting truck traffic to within the daily time period gf 9 am to 4 pm from Mat= 1st-Nov 30th,and irithin the daily lime period gf l0 am to 3 pnu from Dec. ls•t-April 30th. Restmuse I'eak Materials appreciates CPl9's guidance and recommendations with regard to traffic timing and management. Blue Riper Fishery The reach of the Blue River Between Silverthorne Town Limits and Green rt?ountain Reservoir previously held Gold.,Vedal status and was delisted in 2016. The duality of this fishery had been in decline due a variety of impacts including unnatural stream flows,sparse aquatic invertebrate populations, low nutrient content and degraded habitat. The Blue River Enhancement Working Group(13REW)has been working cooperatively to monitor the river condition and idemft what is causing the decline in qualitt=. Macroinvertebr•ates may be sensitive to changes in water qualityfronr the proposed mining activity', and impacts mat further degrade this fishery.Possible impacts to macroinvertebrate health way not addressed in the application. CPW'.suggests for macroinvc:rtebrate impacts•be addressed itt one of two wgvs, if Trot both.Peak.tlaterials could design and implement a robust rnacr•oinveriebrate monitoringprograrn on the Blue River;for which,Peak Materials could explore a partnership with the BREW group. Furthermore, Peak Materials could bolster its water quality monitoring to include.sites in the Blue River downstream gf'the thine,as well as the "wet cell"raining pit itself.tfwater quality impacts are detected in the Blue River or nearby ground iwater, or if a decline in Inacroinveriebrate populations is observes/in the Blue River,and determined to be associated with the miming operations, C'pW requests that the operator address and resolve them immediately. Restonse Peak Materials is already a stakeholder o.fthe Integrated Water Management Plan headed by Colorado Trout Unlimited and the Blue River Watershed Group. It is through this organization that Peak.Materials works to Nupport monitoring and evaluating water quality in the Blue River. Peak.Materials xvill conduct water sampling within the Phase'-'gn-oundwater lake and report the results to CDRMS. Peak Materials will facilitate a N. rmanent access for Colorado-Trout unlimited to the Blue River both during and after inin.ing activities to allow for river studies and satnpling as desired by the Blue River Watershed Group and tile Blue River Enhancement Working Group. C1'W's Water Quality staff has r evieu ed the application and noted that the bedrock under the proposed gravel mine is Pierre Shale, which contains contaminants including selenium,su fate, salts, nitrate, and a variety gf radionuclides that can be released if crushed by gravel mining operations. Of those,selenium is the biggest concern for aquatic life and bir ds as it is binaccrrmulates and souses deformities in the cff,'spring c f all egg-laying organisms, including,fish and birds. Exposure of'the shale bedrock layer could result in significant impacts to the dolnstream frshety in the Blue River,as well as riparian bird species. &-chibit D gf the application.states that the proposed mining will slop at least two feet above the bedrock to prevent its exposure. C'Pti'is concerned that the 2-1oot buffer is too narrow to reasonably avoidpotential exposure gf the bedrock, and recommends cr mininrrun buffer c f 4 feet above the bedrock to prevent accidental puncture or exposure gf the bedrock and subsequent contamination of the Blue River. Restwnse Bedrock will be protected from accidental exposure at the Peak Ranch Resources:in the same manner it is protected at Maryland Creek Ranch:operations at the Maryland Creek.Ranch find that the size of'cobble dramatically increases within 4- 6 feet.ofbedrock.The cobble reaches such a size that the excavator operator is able to feel the change in material."This change in material is used with success at Maryland Creek Ranch to identify the bottom of the minable deposit while staying off of bedrock. Furthertnore,water swupling within the Phase 2 pond during mining will tell Peak Materials if at y selenium, ` _. It 3f++:.5"vii'r',t X x.YB P•;V.S 1..:!. Response to C'1•1W Co;nments on Peak Ranch Resource 2 of'6