1997-04-22_REVISION - M1981302 (9)

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�.i . • NSA • Natural 95cience Associates, Inc. 4814 W. Moorhead Cir • Boulder, CO 80303 • (303) 499-5014 April 20, 1997 The Colorado Mined Land Reclamation Board c/o Division of Minerals and Geology h�'K1.2r2s1�] 1313 Sherman St., Room 215 Denver, CO 80203 DQjX4�ion ot..Miq.tralsB�.Gen!oAY Dear Mined Land Reclamation Board: I am writing to object to Amendment AWI-002 for Western Mobile Inc.'s Deepe Farm Pit, File M-81-302 and to request that the amendment not be accepted. There are two major realms in which I see serious problems with the amendment, and two other concerns about the reclamation of the Deepe Farm Pit.. DECREASE IN LAKES The first serious problem is the decrease of lakes from five (5) to two (2) with a corresponding decrease in acreage from 38.1 to 4.2 acres. The mine operator has committed with DMG to restore wildlife habitat as the end use. The proposed amendment is not technically a good reclamation plan because the decrease contradicts the goal of reestablishing wildlife habitat. Furthermore, the mine operator (which was Flatirons prior to 1989) made several written commitments prior to 1988 to "high quality reclamation " (from 4/21/82 letter) and to restoration of open space. (Please see my letter of 7/15/96 to CMLRB for detailed documentation of this and for references to Colorado's legal requirements - items #1 c, d, e, f, g, h, i, k). However, in 1989, the DMG amendment for the Deepe Farm Pit says "until development occurs". And in 1996 Flatirons signed an agreement (4/25/96) for purchase of the property by the University of Colorado that stated the intent to "maximize development" potential and "development flexibility". The decrease in the lakes proposed in amendment AM-002 is intended to achieve these latter goals and ignore the earlier legal, written and verbal commitments to restore wildlife habitat. I believe that public trust of mining companies and public acceptance of mining activities is undermined by mining company actions that reneg on prior commitments. I urge the Board to uphold the integrity of the mining industry and enforce its own requirements to restore wildlife habitat. FLOODPLAIN IMPLICATIONS OF THE BERM The second major realm is the floodplain implications of the flood control berm and contours shown on the reclamation plan map submitted as part of Amendment AM-002. This map explicitly shows a flood control berm around the eastern edge of the permit area