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0 agriculture purposes to reclamation goals which are more suited to future land development purposes. The City of Boulder finds this :apparent mission change for reclamation at the Deepe Farm Pit ironic in the face of claims Westem Mobile is making as part of its request for a gravel mining permit at a site in Hygiene. Representatives from Western Mobile have touted the company's commitment to a reclamation plan which will tum the mined property into `lakes and wildlife habitat" as grounds for approving its permit request for the Hygiene site. The City of Boulder, for one, must view such reclamation commitments with ajaundiced eye. We only hope the Colorado Division of Minerals and Geology (DMG) recognizes that the credibility of future commitments to mining reclamation standards, and the willingness of local governments to grant future mining permits, depends on the reliability of previous reclamation plans. Impacts on Ground Water Levels and Irrigation Flows The City of Boulder Open Space Department has land holdings adjacent to the Northeast, East, Southeast, and South boundaries of the property on which the Deepe Farm Pit is located. The City of Boulder is concerned that the proposed reclamation plan amendment for the Deepe Fann Pit mining site which Westem ]Mobile is proposing will create adverse impacts on the adjacent Open Space land, with particular concern for potential impacts on ground water, vegetation and access to irrigation water. The City of Boulder Open Space lands contain known populations and habitat for various rare, threatened and endangered species which are dependent on the ground water and irrigation systems that may be affected by the amended reclamation plan. For example, known populations of Ute ladies' tresses orchid (Spiranthes dihrvialis) are located on the Opera Space properties to the east and south of the Deepe Farm Pit mining site. In addition, the wetlands on Open Space lands along South Boulder Creek provide potential habitat for the Preble's meadow jumping mouse (Zapus hudsonius preblei), a species that has been proposed for listing under the Endangered Species Act. Due to the above concems, the: City of Boulder does not believe it is appropriate to approve the proposed amendment to the existing reclamation plan for the Deepe Farm Pit until Westem Mobile conducts a thorough evaluation of the potential ground water and irrigation system impacts for adjacent Open Space lands. Specifically, this evaluation should determine what affect the revision from 3 8.1 acres of surface water to 4.2 acres will have on ground water levels and irrigation flows within the adjacent Open Space lands. The City of Boulder wishes to insure that the reductions in surface water which the proposed reclamation plan amendment incorporates do not result in adverse impacts to ground water levels and irrigation flows on the adjacent Open Space properties, threatening the habitat for the Ute ladies' tresses orchid or the Preble's meadow jumping mouse. Further evaluation of the proposed reclamation plan amendment will help to insure that Westem Mobile has accurately accounted for-evaporative depletions from the remaining surface water and has an augmentation plan in place which is consistent with Colorado law. In this respect, the City of Boulder is particularly concerned that evaporative depletions not have any impact on Colorado Water Conservation Board instream flow water right for South Boulder Creek, as adjudicated in case number 80CW379.