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JUN-29-94 WED 15 23 CITY BOULDER OS/RE FAX NO, 30344429 P. 03 additional fencing and habitat. Problems such as these require that the specifications for stockpiling topsoil should be clear, specific, and detailed. Proper angles of repose with setbacks from property lines should be strictly enforced by the State. Additionally, prolonged stockpiling kills soil microfauna that are essential for reestablishing native plant species. Stockpiles which are not covered also become vectors for weed seeds. The proposed reclamation plan should provide more detailed information on topsoil handling. The existing mine west of the application area has already contaminated the proposed topsoil with noxious weeds and seeds. Wind. and Water Erosion Problem The application addresses the problem that the native soils have with wind and water erosion, however, no methods or specifications for protecting these native soils from these effects are proposed. The present method, followed by the applicant on its existing mine, to allow weed growth as an alternative to proper wind and water erosion prevention is unacceptable to us. Vegetation recovery with the Topsoil The application states that the "Vegetation will be recovered with the topsoil material." No mention is made of how this will occur or how the material will be handled. Noxious Weed Infestations Our primary concern in opposing this application is the applicant's failure to control the noxious weeds on the existing mine sites south of our property. These areas have severe infestations of diffuse and spotted knap~weed. These knapweed species are included on the list of noxious weeds requiring management under the Colorado Weed Management Act. Accordittg to local ranchers, this infestation was not present in the mined area west of the proposed permit area prior to the mining operations currently being conducted by the applicant. Open Space has expended considerable resources over the past three years to reduce knapweed populations on our adjacent properties. We anticipate that substantially more resources will be required over possibly ten or more years before the population is reduced to acceptable levels. Dalmatian toadflax is another significant noxious weed in the area which is not addressed in the permit application. Expansion of Western Aggregates' operations into other areas before the knapweed situation is properly addressed will result in considerable expenditure of public resources on weed control and large inputs of toxic herbicides into the environment. Preventative measures, i.e. control the knapweed in the existing and proposed permit area BEFORE starting additional mining activities, aze the key. The Noxious Weed Management Plan in the application appeazs to be a plan for the existing mining operations and does not specifically address the proposed permit area. It does not include evaluation data that should be available for recent weed management efforts on existing mined aeeas. Evaluation of such data would help us determine if Western Aggregates' weed management efforts have been successful Ori their existing permitted areas. Coordinated Weed Management All weed management efforts should be wordinated with the City of Boulder Open Space IPM Coordinator (Laurie Dieter), with the Boulder County Parks and Open Space Natural Resources Staff (Cindy Owslcy), and the Colorado Department of Transportation. Rioarian Areas urfar~drology-