2002-04-08_REVISION - M1976020 (13)

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Quite frankly, it is not an oversimplification to summarize that this application proposes: Removal by mining of the currently-existing and very substantial rock terrace (on which there are located three elevated and abandoned sewage ponds) which forms the current west bank of the Animas river. 2. Formation by mining a single large and deep lake immediately adjacent to the west river bank but with lake level much lower than the current terrace elevation and a proposed lake depth which is much deeper than the river bottom immediately adjacent to it. 3. Maintaining indefinitely a stable west bank of the river channel (even during severe flooding) adjacent to a the large new lake by means of a combination of an upstream deflecting rock jetty and the replacement of the large rock terrace currently forming the west back with a modest (both much narrower and much lower) burin supported by of concrete blocks that would be tied together by rebar, between the river and the lake. The Lewicki report claims that: • No other lands will be affected by the operation -p. 49 • No buildings or structures outside the permit area could be affected -p. S6 • Since the lake will be mined to 3.OH:1.OV slope, its stability can not be questioned -p. S6 The lake and the river boundary stability can indeed and should be questioned - as should the modifications of the river channel that might result from any number of failures of the proposed system. Current conclusions appear to be based upon many assumptions and oversimplifications. Potential risks and the corresponding impact on wetlands, homes, and property have not been adequately addressed by the applicant; both should be addressed before an application is approved. For example, the Lewicki report directly admits on page 8 that the river channel is changing annually and on page 9 that a stable river bottom grade is essential to control damage during a large flood. We agree with these statements. The river channel moves under moderate flow and surely, and under future flood flows, there are risks associated with the long-term stability of the river channel, with the proposed elimination of a major rock terrace and the introduction of a nearby lake. The stability of the proposed hydrological modifications under flooding conditions is not at all clear. Furthermore, the consequences down-river could be major, if the proposed hydrological controls (burins, protected embankment, and rock jetties) become compromised and the proposed adjacent lake encourages movement of the river channel flow to the west of the current channel boundary during flood flows. Neither the risks nor the consequences have been thoroughly evaluated by the applicant. We, and other down-river residents, should not be asked to risk our homes and our livelihoods so that large amounts of river rock can be conveniently mined so close to the