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JUL-28-94 THU 15 ~ 05 • FAX N0. 303 9~¢ 4775 P. 06 ~~~Fr 94-DOB-08336 Mr. Berhan Keffelew State of Colorado Reclamation Division 1313 Sherman Street, Room 215 Denvi:r, CO 80203 Dear ]vIr. Keffelew: Thartl~: you for the opportunity to comment on Western Aggregates permit request for what is commonly referred to as Section 16 located in Township 2 South Range 70 West, east of Highway 93 and north of Highway 72. The following is a brief summary of our concerns regarding the proposal. The proposed site of the Section 16 mining operation is upstream from some unique hydrologic features within the Rocky Flats Buffer Zone. The Antelope Springs area, located downstream from the proposed mining operation, is considered a unique habitat for numerous species. Information supplied to date from WAI is insufficient in detailing how they intend to preclude alteration of these habitats and hydrologic resources in the area. If it is correct that the Rocky Flats t~lluvial layer is transporting water feeding the seeps, it is possible that mining the alluvium upstream might drastically affect the downstream hydrology. It is also possible that major excavation in this area might be a serious threat to the downstream habitats. Substantial additional information should be required regarding the hydrology and the flow of water through the pediment. Several assurances aze necessary in terms of water quality. Assurance is needed that al.l water used in the mining operation stays on the excavation site and that there is no dumping of water down gradient without changing the flow patterns downstream. In addition, it is imputative that the hydrology of the area be maintained either naturally or manually in order to maintzun the Antelope Springs and Woman Creek drainage. The r:ulroad easement which generally runs north to south, east of Phases 3 and 4 shall be maintauned with no encroachments. Proper line of site and all appropriate safety measures shall be maintained at all times. Habitat losses in the Woman Creek drainage and Antelope Springs which might occur from the proposed mining of Section 16 may be significant but may be mitigated. We recommend that more hydrologic analysis be undertaken prior to, or as a condition of, this request. We have been in contact with Richard Meyers of Western Aggregates and have discussed the above issues. We aze confident that these matters can be satisfied in manner that is positive for WAI and positive for the ecology of the Smart Ditch and the Wottman Creek drainage. If you have any questions regarding this matter, please do not hesitate to contact me at 966-5926. Sincerely, Joseph D. Wienand Planning and Integration