1997-05-06_REVISION - M1981302 ‎(13)‎

• Permit No: M1981302
• IBM Index Class Name: Revision
• Doc Date: 5/6/1997
• Doc Name: HANDWRITTEN NOTE
• Type & Sequence: AM2
• Media Type: D
• Archive: No

0�/12/1997 2E:52 3034995014 JANE BUNIN PAGE 02
NSA • Natural Science Associates, Inc.
48i4 W, Moorhead Cir • Boulder, CO 80303 • [phone]
May 12, 1997
The Colorado Mined Land Reclamation Board
c/o Division of Minerals and Geology
1313 Sherman St., Rm 215
Denver, CO 80203
Dear Mined Land Reclamation Board:
I am writing about Western-Mobiles Deepe Farm Pit in Boulder. FIRST, I wish to state that I
am still concerned about the issues already submitted in my April 20, 1997 letter. SECOND, I
suggest that the 5-6-97 list of issues would be clearer if grouped by topic. For example, the main
topic "End Use" is now addressed in items# 1,6,7,8. The main topic "Floodplain Concerns" is in
items#3,4,5,9. "Other Issues" include# 2, 10, 11. For the Floodplain Concerns, items#3 and 9
are closely related. "Floodplain implications of leaving the berm" underly both 3 and 9, and 3 and
9 are suggestions to address implications. I strongly support item 9: "Berm(more properly dike
or levee) plans should be consistent with whatever the ongoing floodplain studies indicate".
THIRD, in 1996, citizens and consultants to C.U. discovered that acreages of land within the
Deepe Farm Pit that were mapped within the 1979 floodplain were incorrectly removed from the
1988 FMM trap due to faulty dike data. See the 10/4/97 letter from the CWCB to C.U. and the
10/11/96 letter from the City of Boulder to Boulder County.
FOURTH, the dike is a DMG-regulated feature since it has been affected by the mine operator.
The dike in the amendment AND in the "T.R. dated 5/2/97" have large implications for both end
use and floodplain issues that involve serious health and safety concerns. FIFTH, this means that
the "T.R." should be an Amendment and should be heard before the Board in the event that the
DMG approves the "T.R." SIXTH, I wish to add an issue: The proposed dike is not maintenance
free, whereas DMG requires that reclamation features require minimal maintenance. If built as
proposed, to meet FEMA criteria, the dike has very stringent maintenance requirements
1N SUM, in order to act responsibly and credibly, CMLRB must consider context and end uses of
reclamation features. The context at the Deepe Pit includes serious floodplain issues under other
jurisdictions that would be undermined by approval of this amendment or T.R.. For example, the
City and County of Boulder are strongly opposed to approval of a permanent dike prior to
evaluation of alternatives. UDFCD now has ongoing studies of alternatives expected to be done in
several months. The end use of development is not approved by DMG, yet the proposed changes
are intended for this use and seriously detract from the approved end use of wildlife habitat.
Thank you very much for your attention to these concerns.
Yours ly,
Jane Bumn, PhD, Ecologist