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~` March 19, 1999 Wally Erikson r~ r~ Division of Minerals and Geology Durango Office i~~E~!/C~ 484 Turner Drive Building F#101 ~ ~ t, ,,,,, Durango, CO 81301 ~ ~" ' 2 " ~~ ~:; Re: Delta Paving Gravel Pit PermitApplicationM-98-105 °` °iaerais ~ Geology Dear Mr. Erikson: 999 Received MqR 2 6 15gg Divis~~ran~ Fie +e9 era/~ dry. & Gevtp~, D,~ ~ _ _, , ' ~/-~ ~.~L~La~ ~/L~ ~~~~ This letter constitutes the comments of the Western Slope Environmental Resource Council (WSERC) regarding the DMGTermi_rap lirarinn lined abovE. $~~ZZ WSERC is a grassroots non-profit conservation organization based in ~4 ~~ ~LIJ~ Paonia, CO, and dedicated to protecting and enhancing the environment PP ~~~o,~ ` and quality of life in Delta County and Colorado's Western Slope. WSERC F~-r~, organized in 1977 and now has approximately200 members. i~actc of industtial~evPlctpment on wildlife habitat, water quality and the integrity of the Gunnison River are of great concern to our membership. Our members live adjacent to the proposed gravel mine and asphal[gtlant,ltse the riverfor boating, fishing and wildlife watching and travel the proposed haul roads en route to home, school and work. The presence of a gravel pit operation has the potential tnimpact our rural_qualiiy~f Gfe in many ways: from noise, dust and light pollution, to effects on private property values and the impacts on public waters. We recognize that only local county government and not DMG has the jurisdiction to turn down gravel pit applications based on impacts other than those associated withleclamation. And,givenihel'actlhatDelra County currently has no land use codes and there is a market demand for gravel„we can only assume that the development of this pit and asphalt plant are in all likelihood inevitable. Given h~at,1tis nurgoa! Shat this operation be tamed out in a way that impacts to people, wildlife and the aquatic and terrestrial habitats are reduced to a bare minimum and that Grand.htnction Pine a. n~n,ry commitslo rr~~*+~++ *+ cra ~tardc that are acceptable to the local community. By far, the greatest concern is protection for the riparian areas that lie within the permit application boundary. As the DOW report notes, this is an area of extreme importance for wiLllife.and isaJrabitat type that is already limited in this region. Loss of this area would be irreversible in this century. To this end, we ask that DMG take the recommendation of the DOW in requiring as part ofshe mining.~ilart thaI the Grand Junction Pipe and Supply Co. place [he processing plant far away from the riparian areas and construct no permanent ponds within the 50 year Flood plain. We alsa ask that the dPlinearinn >~ fP/tPrll jurisdictional wetlands and the recommendation of the Army Corps regarding the importance of this type of riparian areas be taken seriously by DMG and the applicani_As DMG is in the~r+~cirinn nfapproving the permit boundary, we ask that you consider redrawing the boundary to permanently exclude from mining the critical riparian habitat. We also ask that you consider seriously the issue of developing a mine in an area that could potentially see the yearly release of 10,000 cfs by the Bureau of Reclamation. Astable channel cuasntlyrxists3nJhe river next to the proposed mine. How would the applicant/DMG uphold bank stability if the high flows become reality? Unstable banks combined with such high flowsinmldlead [o greatly increacert fiver $oX 1612 paoniyt CO $1428 Phone S' F>ix 970x527-5307 wserc(p rmi,net