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4 i <br />velocity and a possible change in the direction of the river that would be devastating to downstream <br />landowners. <br />In terms of reclamation, it is our understanding that the applicant intends to donate this land to Delta in the <br />form of a park, once mining is complete in approximately 30 years. It is our posirinn.that a riverside_park <br />with duck ponds is not an adequate replacement for the loss of a complex and diverse piece of riparian <br />wildlife habitat We request that the goal of reclamation be a complete restoration of the wetlands habitat <br />and we support the DOW's recommendation that this include transplanting appropriate vegetation. The <br />proposed vegetation replacement is inappropriatelo the riparian hahitar consisti°v~cnlPly of~tyland <br />grasses where there should be sedges, rushes and cattails. In addition, the DMGshould go beyond <br />simply grading the area in 2 tol and 3 to 1 slopes to require a more natural and ecologically appropriate <br />design that includes shallow and deep water habitat. To that end, we ask suggest that hiring an <br />independent party or team including an environmental engineer, biologist and ecolggist,lcaincd ~n hah;rar <br />replacement would be an appropriate. Confluence Pazk could perhaps serve as amodel in this pursuit. <br />In regards to the plan to allow the river to "reclaim itself' i¢ Phase [I, we find thislecommendatian <br />inappropriate. Without vegetation in place, it leaves the bank prone to infestation by noxious .weeds and - <br />non-native species like russian olives and tamarisk whoseseeds travel in the riverand rend2o n~~+~0~°PrP <br />native vegetation if given the opportunity. The bank should be stabilized and planted with plugs of native <br />vegetation. <br />Also, we expect that the requirements under section 404 of the Clean Water Act, requiring wetlands <br />replacement prior to construction disturbance be upheld. <br />But outside of the specifics of this proposed mine and reclamation plan is an underlying issue that deserves <br />DMG's attention. As you may know, there is currently a cloud on the county lantl~Litts. Local residents <br />and the Delta county commissioners are wondering how the approximately 40 acres contiguous to the <br />wetlands and riparian azea discussed above could have been sold to Grand Junction$peaudSu~ily~or <br />the purpose of gravel mining in the first place. Last year the previous owner requested and was granted by <br />the Delta County commissioners permane¢t agricultural status for this land, sayinghe wanteditlo `remain <br />green forever". Apparently, this request was left out (possibly illegally) by the county land surveyor when <br />finalizing the land platts. The commissioners are Lurre¢tlysnncidp~ going to crLrt r~ arldrrcc and <br />remedy this mistake. With this cloud on the platts, the applicant may not actually have the legal right to <br />mice in that area. Based on this situation, we feel the DMGshould~elay processirlgShis~emut <br />application and issuing a decision until after this land use discrepancy is resolved. <br />We appreciate the opportunity to comment on this perm~r ~ti~ar;nn and thank youfarlhelime_ynuJiave <br />committed to educating us and the public about the project. <br />Sincerely, _. <br />Tara Thomas <br />WSERC Community Organizer <br />