PERMFILE67748

• Permit No: M2000113
• IBM Index Class Name: Permit File
• Doc Date: 4/9/2001
• Doc Name: FAX COVER SHEET
• From: DMG
• To: BALAZ & ASSOCIATES
• Media Type: D
• Archive: No

LEwVENWORTH & KAI~, P.C. •
~[' Army Corps Public Notice Number: 200175036
=i Page 3
1 March 30, 2001
Garfield County Floodplain Special Use Permit; (4) City of Rifle Watershed Permit; (5) Colorado
Department of Public Health and Environrttent NPDES Permit; (6) Federal Aviation
Administration notice and approval relative to waterfowl hazards that may be realized as a result
of activity-created lakes within the aigation easement of the Garfield County Regional Airport;
(7) Compliance with the Endangered Species Act; (8) fugitive dust notification; and (9) water
augmentation plan for lake evaporation and water consumption. Numerous additional issues will
1 be raised by the permitting processes for those permits as well. Accordingly, the City believes
that an Environmental Assessment or an Environmental Impact Statement is necessary to analyze
all of the potential issues and impacts presented by the proposed mining operation before the State
~~ Water Quality Control Division and the Army Corps of Engineers commit themselves to issuing
the requested permits to Applicant.
B. Geomorphologic and Hydrologic Issues
1. Division of Minerals and Geology Adequacy Review
The Colorado Division of Minerals and Geology (DMG), through its adequacy review
process, identified several issues with the proposed mining operation that have not been resolved.
See Exhibits D, E, F, and G. With regard to geomorphologic and hydrologic considerations,
some of the Division's concerns include: (1) reducing the pit slopes to 2:1 or 1.5:1 in order to
minimize the chance for Ute Colorado River to capture the pits, causing a slope failure; (2)
location of topsoil stockpiles out of the floodway of the Colorado River; (3) location and design
of barriers to provide protection against a 25-year flood event; (4) what measures will be
employed to protect domestic wells of downstream water users in the event of a contaminant spill
or leak; (5) providing a detailed reclamation plan, including specific wetland mitigation measures
and revegetation plans; (6) the potential for adverse impacts to the alluvial groundwater system;
r (7) minimize sedimentation of exposed alluvial-groundwater; (8) cazeful handling of wetlands soil
to preserve the integrity and viability of the soil and to assure that the wetlands soil is not mixed
with sand, gravel or other types of soil; (9) implementation of stabilization methods for riverside
pits in order to prevent destabilization during a flood event; and (10) dam safety and floodway or
't . floodplain impediment issues created by the installation of water impounding berms between
gravel pits. See Exhibits D and F. (For a complete discussion of these issues and others
' presented by the DMG Adequacy Review, see attached Exhibits D and F.)
The DMG Adequacy Review Comments point out several geomorphologic and hydrologic
inadequacies of Applicant's proposed mining operation. Each of those issues should be resolved
before Applicant receives any permit for its proposed project. Accordingly, the City of Rifle
incorporates the above comments, as well as all others contained within the DMG Adequacy
Review Comments, as its own.
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