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~V: ~ PAGE 21/70 <br />result fzom such use. <br />68. Defendant DOE has not taken action in compliance with <br />EO .11990. Wetlands within the Buffer Zone are federal property. <br />Defendants DOE manages these wetlands. Defendants DOE has issued <br />WAI licenses and easements and entered into agreements with WAI <br />authorizing the use federal property. <br />69. Defendant DOE has not minimized the destruction, loss, <br />or c:egradation of wetlands in the Buffer Zone, including those <br />wetlands within the Rock Creek drainage. Defendant DOE has not <br />taken steps to preserve or enhance tha natural and beneficial <br />values of the wetlands within the Buffer Zone. Defendant DOE has <br />not =onsidered conservation and long-terra productivity of the <br />wetlands, important habitat for the Preble's meadow jumping <br />mouse, the rare xeric tall grass prairie, or the Rock Creek <br />drainage. <br />70. Defendant DOE has not made a finding that there are no <br />practicable alternatives to the sand and gravel mine expansion. <br />Defendant DOE has not made a finding that the mine expansion <br />includes all practicable mitigation measures. <br />71. Defendant DOE has not avoided providing assistance for <br />construction in areas containing wetlands. Defendant DOE has <br />assisted wAI in its appligations for a state mining permit and <br />Jefferson County rezone. Both the permit and rezone were <br />neces,~ary for the expansion of WAI's sand and gravel mining <br />operations. <br />Seovnd Amcndcd Complaint <br />20 <br />