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Applicant's Response to Second Adequacy Letter <br />Grand River Park Project, DRMS File M-2006-046 <br />January 2, 2007 <br />Page 22 <br />"indicate how the cottonwoods and wetlands will be monitored and protected <br />from such impacts." In its first adequacy response, the applicant provided <br />information concerning the anticipated role of cottonwoods and wetland <br />resources in the reclamation plan and identified the appropriate level of <br />protection for these on-site resources. For reasons that are unclear, the Division <br />apparently did not accept the resolution of Comment 25 offered in the applicant's <br />initial adequacy response. <br />The bulk of the Division's new request (articulated in italics above in the present <br />version of Comment 25) is premised on the existence of "wetland resources <br />and/or woody vegetation resources such as cottonwoods or willows that occur <br />between the proposed pit and the main channel of the Colorado River." <br />According to the Division's Comment, further study and mitigation is required if <br />Cottonwoods or wetlands are located in the specified zone, between the <br />proposed pit and the Colorado River. <br />As an initial matter, wetland resources are not present in the zone of concern. <br />Wetlands are located to the interior of the site and are subject to avoidance and <br />other mitigation measures as described in the Water Management Plan. Further <br />information regarding hydraulic barriers, groundwater monitoring, and other <br />mitigation planning is discussed in the attached Martin and Wood adequacy <br />response letter and above in response to Comment 21. <br />Additional clarification of the recent adequacy comment was obtained in the <br />applicant's October 19 meeting with the Division. The Division stated that the <br />regulatory concern referenced in the excerpted language concerning <br />cottonwoods is off-site woody growth, particularly trees that may be valued by <br />neighboring land owners as real estate or chattel property. The Division cited off- <br />site propagation of the cone of depression (in the Martin and Wood groundwater <br />model) as a specific source of concern. The Division also provided the applicant <br />with a copy of an Environmental Managementjournal article entitled, "Responses <br />of Riparian Cottonwoods to Alluvial Water Table Declines." <br />The applicant shares the Division's concern that the riparian functions and <br />character of the Colorado River corridor are maintained under the proposed <br />mining and reclamation plans. As stated in the applicant's initial response to <br />Comment 25, one of the most important benefits to local vegetation is the control <br />of weedy growth, especially noxious weeds such as the Russian-olive and <br />Tamarisk trees that sprawl across the site (see DRMS Inspection report dated <br />06/26/2006) along its northeastern boundary. Mining will result in the clearance <br />and suppression of weeds, discouraging the opportunistic growth pattern <br />responsible for choking out native canopy on the subject property. <br />To be clear, very little native woody growth is found on the subject property. It is <br />believed that significant disturbance occurred on the site during the construction <br />