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perennial when it appears to be ephemeral and restates a known concern as to the erosive potential of the site. Erosion was addressed both by the SCS and the CMLRD. He indicates devalued lands without any supporting evidence. He indicates a known risk of sedimentation, but this con- cern the CMLRD did not pursue prior to this time. He con- cludes with an unsupported assumption that the operation invites similar operations, and does not indicate why this is a significant concern, or relate it to impacts or issues at hand. 21 FEBRUARY 1990: First introductory correspondence from Gambit, Inc. to Elbert County Commissioners and Attorney. 3 APRIL 1990: Correspondence from James R. Taylor to the Elbert County Commissioners. Complains of erosion from the Fondis Mine and impacting Spring Branch and West Bijou Creek. Mr. Taylor claims hundreds of tons of sand and gravel impacted Spring Branch, but offered no supporting measurements or documentation. Mr. Taylor also observes that required berms had not been constructed at the time, a potential departure from the approved CMLRD permit. For the first time, Mr. Taylor expresses his concern for Wetlands, now regulated by the DA. Finally, he expresses a legitimate concern for accelerated siltation of pond from active erosion off of the Fondis Mine. Whether the concern is significant has apparently never been quantified or qualified by adequate measurement or documentation. Of course a pleasant gesture by Elbert County under a Technical Revision may include seeding the impacted stream bed, and cleaning out the alleged impacted pond, replanting some trees, and so forth. A comparatively marginal ex- pense, assuming no guilt on the part of the County is in- ferred by doing so. NOTE: Both the CMLRD (later) and Mr. Taylor are concerned with erosion off the mined area. However, later observa- tions would indicate that much of the sediment from the mined area was from material bladed over the edge of the adjacent Spring Branch. The mine floor is relatively flat, reducing transportation of materials detached and trans- ported (eroded) from mine slopes. Long slopes without establishing cover via concurrent revegetation were more erosive that if left steep until revegetation efforts were possible. Regardless, the mine area was not the major con- tributor via erosion. Pushing materials into the drainage by overcasting, and more importantly, lateral erosion of a perched access road contributed the major source of erosion. This continues to Correspondence of 6/15/91 to Frank G. Starkey, Elbert County Commissioners Office from Bradford Janes, Gambit, Inc. RE: Fondis Mine - Summary Report.