1997-04-24_REVISION - M1981302 - Laserfiche WebLink

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Floodplain Implications The Land Berm The "Reclamation Plan, Deepe Pit, Western Mobile Boulder, Boulder, Colorado" drawing which accompanies the proposed reclamation plan amendment for the Deepe Farm Pit mining site proposes a major land berm around the southern and eastern perimeter of the Deepe Farm Pit. This land berm constitutes a significant new land feature which was not included in either the 1989 or 1991 "Deepe Pit Reclamation Plan(s)" that the Colorado Mined Land Reclamation Board (MLRB) previously approved and constitutes a significant revision to reclamation of the Deepe Farm Pit mining site. It is worth noting that the Exhibit "E," Reclamation Plan discussion in the "Notice of Filing Application" for the proposed reclamation plan amendment makes no reference to the addition of this major land berm. Specifically, these materials simply state that "the most significant feature of the Revised Reclamation Plan is the reduction in the total number of acres of exposed water surface." The City of Boulder believes that failure to reference and address the addition of the land berm in the application for the reclamation plan amendment misrepresents the significance this land feature has on the health, safety, and welfare of citizens in Boulder County and the City of Boulder. For this reason, the City of Boulder requests that the DMG require Western Nfobile to submit additional detailed information about the land berm and relevant impacts on the surroundine community prior to any final determinations concerning the proposed reclamation plan amendment for the Deepe Farm Pit. The City of Boulder understands that the Flatiron Companies, Western Mobile, and the University of Colorado propose to include the subject land berm in site reclamation for the Deepe Farm Pit as a flood protection barrier against the adverse flooding impacts the gravel mine has created for lands downstream of this mining site. Such an action is contrary to previous representations regarding the land berm which were the basis of Boulder County approval for this temporary land feature and is inconsistent with MLRB's adopted reclamation plan for the Deepe Farm Pit mining site. The land berm was originally graded on site as an interim measure to provide flood protection for the Deepe Farm Pit during gravel mining. Previous reclamation plans for the Deepe Farm Pit indicated that this land berm would be removed at the conclusion of mining operations. Western Mobile and preceding mining operators at the Deepe Farm Pit site never represented that the land berm would remain as a long-term floodplain control facility. In this respect, Western Mobile's surreptitious attempt to garner authorization for maintaining the land berm as a condition of final reclamation for the Deepe Farm Pit mining site represents a complete lack of respect for the reclamation plan approval process and a total disregard for its previous commitments. In general, as noted above, the proposed reclamation plan amendment provides no description of the mining and reclamation need for the land berm, no analysis of its intended purpose, and no explanation for the absence of this land feature in the previously approved 1989 and 1991 reclamation plans for the Deepe Farm Pit. Neither has Western Mobile provide a detailed teauucal evaluation of the land berm in the context of final reclamation for the m;n:ng site. This