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_ __ __ __ _ ,., _.,. [D: • PACE 5/30 <br />• <br />12. WAI and Conda have formed a joint venture to expand the <br />existing gravel mine into the Proposed Mining Area, within the <br />Bu]`fer Zone. <br />B; Resources of the Buffer lone <br />13. The Buffer Zone, including Che Proposed Mining Area, <br />sits amidst scenic grandeur and unique natural resources ac the <br />base of the Front Range of the Rocky Mountains. Because it is <br />higher than the surrounding terrain, the Buffer Zone offers <br />magnificent views of the ^Flatirons" rock formation near Boulder <br />as tiae11 as the Denver skyline_ <br />14. The Buffer zone is located on "Rocky F1ats,^ a unique, <br />gravel plain that sits at the base of the Front Range. Because <br />the plain consists of a thick gravel and stone layer, it acts <br />like a sponge, storing water in the pore spaces between the <br />rock:>. The plain is the source of four drainages, including the <br />Rock Creek drainage. vegetation and wildlife prosper in these <br />drainages due to the relative abundance of water. <br />15_ The Buffer Zone is an irreplaceable natural resource. <br />Ecolcgist5 hired by Defendant DO& have judged it to be ^one of <br />the most ecologically sensitive areas in the Buffer Zone, and the <br />area most in need of protection from construction and <br />devel~~pment.° In addition, the Colorado Natural Heritage Program <br />(°CNHS>'! determined that the area contains "significant natural <br />heritage resources,° those species or communities determined by <br />CNHP to be rare, threatened or endangered or of high <br />significance, and denoted the area a "natural heritage site " <br />SeCafa An,tnded Complaint <br />5 <br />