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December I7, 2004 Pave 2 This is an area of very steep slopes, thin soul with srenered conif er trees. It is hard for me to see hem• be plans na divert the s[r>~im amuixi his processing site, as the sttcttns there are alrrady incised deeply (Figure 1), and moving them will require a good deal of mining first of all, acrd will cause a scrod dril of dismption nhen rmbid swan-avttter nmoff rarr}vng fines and rrx:Jt dump into Clear Creak daring aril of ter such relrx :tritm . Under the Clean Water Act I datM if the proposed diversion of the small streams and the buildung of a small "smiling basin" will br adegrralely rapable of odleaing the mining fines and crushed particles that map 6e moved ~' stormwaler . A permit Mkt from the US Corps ctf Etgineets siting pennissioa to Fill the drainage wa}~s memioned here has not been sought An additional n•ater pmblem will result frram Wolf's >med [o bring in some 30,(XX) gallons of water per dap for dust control to this small bedrock area ]n 5 da}s this volume is ]50,(X70 gallons, and (itX),tXX) ua a moath. Quite a lot of water more than the aatural pteripitatuoa provides. Mr Wolf sa}:s he ma}` tied to dig a tined pond or cis[em "to store this water near the plant si [e"(P. 18). Where? The sp~at-e is very cramped. [f the ephemeral crceks during staras do not create a problem For North Char Creek, this large volume of new water dumped regularly on the site Hill certainly do so! This action exacerbates the pmblem resulting Crum relocating small streams mentioned above and digging a. rettling pond. Urxlerthe Clean WalerAct has amorte calailattxl the amwml of waste rack, minerals amt heacc metals this operation will produce in the Clear Creek dminase? 1 do ~ see any data concerning this pollution pmblem in proposal M-20(11aX~7. Cle.[rly these water problems Hill have considectble environmental impact, and the inlbrmation about st>ch impacts is lacking here. t ante that the CDPS stern-water permit has nor 2aeen applied for. Storm-water damage to Clear Creel; is a good reason why such a permit might be denied. A real concern is that there is very little room betacen the cliffs and the Hiway and the river for ae adequate "rettling basin" or "lilted (storage) pta>d or cistern" to oattrol the storm-Hater and erositxt mr[otT from the mine atra. 77mimge: Hon' is the slam-water from the tame acrd plant area gyring to crass Hinny 119 and enrer Nottit Clear Cteek'1 Is the existing passage under Hiway 119 adequate for all the new stonnwater rundf, (and tntcked wafers for dust control) some of which is going to ccxrtain much more suspended sulirks than uow? W hat is [hat passage? IC it is a cuh ert, is it big emwgh? ]f the mining will impact part of (SW 114 SW 194 Sec. 23) Cottonwood Gulch, this is no "epihemem! stream"! We hzve n•ater rights and measurement dart, and this stream Roar oatttinrtorrsl}' is all seasons. RESI'ORATTON in as much as the paaject in this proposal doer rto[ seem [o have an end, it is important m know nfirm (in what veer) and where (in Sections ?5, ?b, acrd ?3) restoration will begin. The proposal tlo¢s mat Seem to tell us (ext~p[ in general terms about "when the mining is dcme'~ When will that be? The proposal says [ha[ Mr Wolf "Hill appl}' after 10 years, as [he potential is For 100 million tons or more". The tool rainfall doting the year is onl}' 8.8 inches, not adequate for restomtuon by seed to succeed after minine. Once the soil is disturbed and only rae-k is the main exposure, it is unlikely that sees will succeed and mow to maturity. Even when soil is placed on the Mauer suri~aces, the soil will be chin arxd has 0o natvra! mater storage u-tpacit}. When the soil is placed on >a}'ers of the crusher fines (100.0(X) cubic }girds per acre) ,the problem of rramral storage urpacit}- is n-orsened because of the porosity of the crashed Hack (cartslrer fines). Water will penblate easily through this bed of [rack fines, and the small amount of