PERMFILE52747

• Permit No: M2005065
• IBM Index Class Name: Permit File
• Doc Date: 12/22/2005
• Doc Name: Second Adequacy - Upper Animas Sand and Gravel
• From: DMG
• To: Charles Ponchak
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman Sc, Room 275
Denver. Colorado 80203
Phone: [phone]
FAX: [phone]
December 22, 2005
Charles Ponchak
RECEIVE
JAN'D 3 2006
UlrisianotcL ..
Geological Consultant
15292 6950 Road
Montrose, CO 81401
RF: Second Adequacy Issues for a~Comp el x 110c Application,
Upper Animas Sand and Gravel, File No. M-2005-065. t°'~
Dear Mr. Ponchak:
COLORADO
DIVISION OF
MINERALS
GEOLOGY
0.EC LAM ATION•MINING
SA FETY~SCIEN CE
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cottony
Division Director
Natural Resource Trustee
On December 20, 2005, DMG received response to our November 29, 2005 correspondence.
In the November 29 correspondence, DMG identified five adequacy issues for the Upper
Animas Sand and Gravel application. DMG has determined that the response from the
Applicant, dated December 12, 2005 and received on December 20, appropriately addressed
adequacy issues 3, 4 and 5. However, additional information must be submitted for adequacy
issues 1 and 2 before DMG can approve the application. Details of the requested information
are provided below.
Please be advised that the permit application may be deemed inadequate, and your application
may be denied on January 9, 2006 unless the following adequacy review issues are addressed
to the satisfaction of the DMG.
Adequacylssues
Approximately 60% of the proposed permit area is a low-lying and sparsely vegetated gravel bar
of the Animas River. Portions of the proposed excavation area approach the low flow channel
as close as 50 feet. Seasonal high water channels pass through the excavation area. Evidence
of active erosion of the channel was observed during the pre-operation inspection for the reach
of river adjacent to the permit area.
1. Due to the proximity of the proposed excavation to the river channel and unconsolidated
nature of the material between the river channel and excavation, there appears potential for the
current erosion of the riverbank to advance into portions of the excavation area. Under such a
scenario, the proposed mining activity has potential to destabilize the river channel by head cut,
tail cut and lateral erosion occurring as the 15-foot deep pit refills with sediment. The proposed
vegetative cover, composed of willow transplants and grasses, will not be planted until mining
has been completed. The application does not demonstrate that the proposed vegetative cover
will stabilize affected lands sufficient to keep the river from eroding its banks and ultimately
capture the pit. Therefore, pursuant to Rules 3.1.5(3), 3.1.6(1) and 6.3.3(1), DMG recommends
that the application include engineered designs, similar to those provided in the Urban Drainage
& Flood Control District manual (1987), and referenced in DMG's In-Stream Aggregate
Extraction and Reclamation Guidance Document (1998), for stabilizing the river channel at its
Office of Office of Colorado
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