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Quite frankly, it is not an oversimplification to summarize that this application proposes: <br />1. Removal by mining of the currently-existing and very substantial rock terrace (on <br />which there are located three elevated and abandoned sewage ponds) which forms <br />the current west bank of the Animas river. <br />2. Formation by mining a single large and deep lake immediately adjacent to the west <br />river bank but with lake level much lower than the current terrace elevation and a <br />proposed lake depth which is much deeper than the river bottom immediately <br />adjacent to it. <br />3. Maintaining indefinitely a stable west bank of the river channel (even during severe <br />flooding) adjacent to a the large new lake by means of a combination of an upstream <br />deflecting rock jetty and the replacement of the large rock terrace currently <br />forming the west back with a modest (both much narrower and much lower) burro <br />supported by of concrete blocks that would be tied together by rebar, between the <br />river and the lake. <br />The Lewicki report claims that: <br />• No other lands will be affected by the operation -p. 49 <br />• No buildings or structures outside the permit area could be affected -p. 56 <br />• Since the lake will be mined to 3.OH:1.OV slope, its stability can not be questioned -p. 56 <br />The lake and the river boundary stability can indeed and should be questioned - as should <br />the modifications of the river channel that might result from any number of failures of the <br />proposed system. Current conclusions appear to be based upon many assumptions and <br />oversimplifications. Potential risks and the corresponding impact on wetlands, homes, and <br />property have not been adequately addressed by the applicant; both should be addressed <br />before an application is approved. <br />For example, the Lewicki report directly admits on page 8 that the river channel is <br />changing annually and on page 9 that a stable river bottom grade is essential to control <br />damage during a large flood. We agree with these statements. The river channel moves <br />under moderate flow and surely, and under future flood flows, there are risks associated <br />with the long-term stability of the river channel, with the proposed elimination of a major <br />rock terrace and the introduction of a nearby lake. The stability of the proposed <br />hydrological modifications under flooding conditions is not at all clear. Furthermore, the <br />consequences down-river could be major, if the proposed hydrological controls (burros, <br />protected embankment, and rock jetties) become compromised and the proposed adjacent <br />lake encourages movement of the river channel flow to the west of the current channel <br />boundary during flood flows. Neither the risks nor the consequences have been thoroughly <br />evaluated by the applicant. <br />We, and other down-river residents, should not be asked to risk our homes and our <br />livelihoods so that large amounts of river rock can be conveniently mined so close to the <br />