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r <br /> APR 22 197 14:18 CITY OF BOULDER ; P.3i13 <br /> agriculture purposes to reclamation goals which are more suited to future land development <br /> purposes. <br /> The City of Boulder finds this apparent mission change for reclamation at the Deepe Farm Pit <br /> ironic in the fate of claims Western Mobile is making as part of its request for a gravel mining <br /> permit at a site in Hygiene. Representatives from Western Mobile have touted the company's <br /> commitment to a reclamation plan which will tam the mined property into"lakes and wildlife <br /> habitat" as grounds for approving its permit request for the Hygiene site. The City ofoulder, <br /> for one, must view such reclamation commitments with a jaundiced eye. We only hop ;;the <br /> Colorado Division of Minerals and Geology(DMG)recognizes that the credibility of future <br /> commitments to mining reclamation standards, and the willingness of local governments to grant <br /> future mining permits, depends on the reliability of previous reclamation plans. <br /> Impacts on Ground Water Levels and Irrigation Flows <br /> The City of Boulder Open Space Department has land holdings adjacent to the Northeast, East, <br /> Southeast, and South boundaries of the property on which the Deepe Farm Pit is located. The <br /> City of Boulder is concerned that the proposed reclamation plan amendment for the De}:pe Farm <br /> Pit mining site which Western Mobile is proposing will create adverse impacts on the adjacent <br /> Open Space land, with particular concern for potential impacts on ground water, vege i4lon and <br /> access to irrigation water. The City of Boulder Open Space lands contain known populations and <br /> habitat for various rare, threatened and endangered species which are dependent on the;ground <br /> water and irrigation systems that may be affected by the amended reclamation plat. For example, <br /> known populations of Ute ladies'tresses orchid (Spirmrrhes diluvialis) are located on the Open <br /> Space properties to the east and south of the Deepe Farm.Pit mining site. In addition, the <br /> wetlands on Open Space lands along South Boulder Creek provide potential habitat for the <br /> Preble's meadow jumping mouse(lapus hudsoniut prehki), a species that has been proposed for <br /> listing under the Endangered Species Act. <br /> Due to the above concerns, the City of Boulder does not believe it is appropriate to approve the <br /> proposed amendment to the existing reclamation plan for the Deepe Farm pit until Wes'am <br /> Mobile conducts a thorough evaluation of the potential ground water and irrigation system <br /> impacts for adjacent Open Space lands. Specifically, this evaluation should determine v'hat affect <br /> the revision from 3 8.1 acres of surface water to 4.2 acres will have on ground water levels and <br /> irrigation flows within the adjacent Open Space lands. The City of Boulder wishes to insure that <br /> the reductions in surface water which the proposed reclamation plan amendment incorporates do <br /> not result in adverse impacts to ground water levels and irrigation flows on the adjacent Open <br /> Space properties, threatening the habitat for the Ute ladies' tresses orchid or the Preble's meadow <br /> jumping mouse. Further evaluation of the proposed reclamation plan amendment will Irlp to <br /> insure that Western Mobile has accurately accounted for-evaporative depletions from the <br /> remaining surface water and has an augmentation plan in place which is consistent with Colorado <br /> law. In this respect, the City of Boulder is particularly concerned that evaporative depl--bons not <br /> have any impact on Colorado Water Conservation Board instream flow water right for South <br /> Boulder Creek, as adjudicated in case number 80CW379. r <br /> Y <br />