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i • water events) will not change the course of flow of the river, nor will the placement of topsoil, overburden and product piles increase the base flood elevation of the river. With the placement of topsoil, overburden and product piles being in the floodplain of the Colorado River and with the pit and embankment slopes proposed to be steeper than 1H:1V, concern exists as to the high erosion potential and thus bank stability of all aspects of the activity. We strongly urge consultation with the Denver regional office of the Federal Emergency Management Agency and the Colorado Water Conservation Board regarding this application. 3. Concern over adequate temporary revegetation is given as related to the proposed pit and embankment slopes. 4. Concern over erosion mitigation, bank/pit slope stability in relation to a continuous mining activity exists. 5. The activity falls within the City of Rifle watershed district boundary and is required to secure a watershed permit. ' 6. As eagle's nests and heron rookeries are observed to exist within the boundary of the proposed activity, concern over habitat disruption is given. 7. Although the applicant has identified the 100 year floodplain of the Colorado River as it relates to this site, the 100 year floodway has not been identified. It appears that some of the mining activities are proposed to occur within the 100 year floodway where no obstruction of flow is allowed. This may impact the hydraulics of the Colorado River by either increasing floodway velocity or raising the base flood elevations. 8. Consideration should be given to assure that adequate bonding is in place to reclaim the property subject to this application, any downstream properties and the geological characteristics of the Colorado River in the event that flooding and changes in the geological characteristics of the river negatively impact each as a result of inadequate mitigation and/or erosion protection. The City of Rifle thanks you for giving us the opportunity to have reviewed and provided comment on this application. We hope you give our concerns due consideration during your review of this application. We are available to answer any questions that you may have regarding this letter. Respectfully submitted: SCHivIIJ;~,$~R G,q~RD,~iJ ivlcY'ER, INC. P.E. Rifle Cily Council Selby Myers, City Manager Lee Leavenworth, City Attorney Bill Sappington, Public Works Director Pat Hopkins, Director of Planning and Development Garfield County Board of County Commissioners Mark Bean, Director of Building and Planning, Gafiield County Don Deford, Garfield County Attorney Bill Balaz,Jr., Balaz 8 Associates D:\work\worddocs\99065a 126.doc