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„~_ __ __ __ ._ ... _.. • lu= ~ PACE 29/30 <br /> <br />jurisdiction over activities within the Buffer Zone violates <br />section 904 of the Clean Water Act; <br />3. Declare that Defendant DOE's actions with respect to <br />the mining company's sand and gravel mine expansion, including <br />the ~aasement and license for road use and construction and <br />authorization to enter the suffer Zone and destroy the <br />hydrological conditions within the Rock Creek drainage, are null <br />and void pending full compliance with NEPA, the ESA, and EO <br />11990; <br />4. Order Defendant DOE through an injunction to comply <br />with NfiPA, the ESA, and Executive Order 11990 with respecC to the <br />proposed sand and gravel mine expansion at Rocky Plats; <br />5. order Defendant Corps through an injunction to assort <br />section 404 jurisdiction over the wetlands within the Buffer <br />Zone; <br />~_ Order Defendant DOE through an injunction to abate all <br />actions within the Buffer Zone which will directly or indirectly <br />cause harm to the wetland and riparian habitat, open space, and <br />the l:,sted Preble's meadow jumping mouse pending compliance with <br />the al:orementioned laws; <br />;_ Award Plaintiffs` costs, including reasonable <br />attorneys' fees and expert witness fees; and <br />B. Provide such other relief as the court deems just and <br />proper_ <br />Second Anlrndcd Complaint <br />23 <br />